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EPA Needs to Demonstrate 

Public Health Benefits of 

Drinking Water State 

Revolving Fund Projects 

Report No. 15-P-0032 December 5, 2014

U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

Protecting America’s Waters
Report Contributors: Dan Engelberg

Khadija Walker

Charles Brunton

Tiffine Johnson-Davis

Gerry Snyder

Abbreviations

DWSRF Drinking Water State Revolving Fund

EPA U.S. Environmental Protection Agency

GPRA Government Performance and Results Act of 1993

OIG Office of Inspector General 

PBR Project and Benefits Reporting 

PWSS Public Water System Supervision

SDWA Safe Drinking Water Act

SDWIS Safe Drinking Water Information System

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15-P-0032

December 5, 2014

Why We Did This Review

We conducted this review to 

determine how the U.S. 

Environmental Protection 

Agency (EPA) and states 

demonstrate that completed 

Drinking Water State Revolving 

Fund (DWSRF) projects met 

project and program goals and 

contributed to improved 

drinking water quality and 

public health. 

The 1996 Safe Drinking Water 

Act Amendments, in part, 

authorize the EPA to provide 

funding for capitalization grants 

to states to further public health 

objectives and promote efficient 

use of funds. The states use 

these funds to support low 

interest loans and other types 

of assistance to public water 

systems. The EPA conducts 

annual reviews encompassing 

certain aspects of the states’ 

programs. 

This report addresses the 

following EPA goals or 

cross-agency strategies:

 Protecting America’s 

waters.

 Protecting human health 

and the environment by 

enforcing laws and 

assuring compliance.

Send all inquiries to our public 

affairs office at (202) 566-2391

or visit www.epa.gov/oig.

The full report is at:

www.epa.gov/oig/reports/2014/ 

20141205-15-P-0032.pdf

EPA Needs to Demonstrate Public Health Benefits 

of Drinking Water State Revolving Fund Projects 

 What We Found

The EPA does not obtain all required DWSRF 

project data from states, despite capitalization 

grants that require states to input key project 

information into EPA databases. The EPA 

also does not always use annual reviews of 

state DWSRF programs to assess project 

outcomes. Without this information the EPA 

cannot determine whether completed DWSRF 

projects contributed to improved drinking 

water quality and public health. In addition, the GPRA Modernization Act of 2010 

(GPRA refers to the Government Performance and Results Act of 1993) requires 

all federal agencies to have long-term goals that are supported by interim 

performance indicators. The EPA requires states to systematically provide 

information that can be used to assess project results. However, not all states 

report complete, required information in every instance. Our analysis shows that 

systems that received DWSRF funding regain compliance, indicating public 

health improvements. However, incomplete reporting affects the overall value of 

our analysis of the DWSRF program. These incomplete data hamper the EPA’s 

ability to evaluate program effectiveness and public health outcomes.

As a result, the EPA is unable to demonstrate the public health results of its large 

DWSRF agency expenditure, which represents about 10 percent of the agency’s 

annual budget. Further, the EPA cannot demonstrate the overall success of 

DWSRF projects. The EPA is also missing an opportunity to capture potential 

best practices of state programs and projects.

 Recommendations and Agency Corrective Actions

We recommend that the Assistant Administrator for Water enforce grant

requirements that states input all necessary data in the project-level tracking 

database and review data completeness as part of the EPA’s annual review of 

state performance. We also recommend that the EPA enhance coordination

between DWSRF and Public Water System Supervision programs and

periodically evaluate program results.

The agency agreed with our recommendations and provided corrective actions 

with milestone dates. The recommendations are resolved with corrective actions 

pending.

U.S. Environmental Protection Agency

Office of Inspector General

At a Glance

The EPA needs to enforce 

grant requirements for 

collecting DWSRF project 

information to demonstrate 

the public health results of the 

$11.37 billion it has invested 

in drinking water 

infrastructure since 2009.
December 5, 2014

MEMORANDUM

SUBJECT: EPA Needs to Demonstrate Public Health Benefits of 

Drinking Water State Revolving Fund Projects 

Report No. 15-P-0032

FROM: Arthur A. Elkins Jr.

TO: Ken Kopocis, Deputy Assistant Administrator

Office of Water

This is our report on the subject evaluation conducted by the Office of Inspector General (OIG) of the 

U.S. Environmental Protection Agency (EPA). This report contains findings that describe the problems 

the OIG has identified and corrective actions the OIG recommends. This report represents the opinion of 

the OIG and does not necessarily represent the final EPA position. Final determinations on matters in 

this report will be made by EPA managers in accordance with established audit resolution procedures.

The office responsible for implementing the recommendations included in this report is the Office of 

Water’s Office of Ground Water and Drinking Water, Drinking Water Protection Division. 

Action Required

The report recommendations are resolved with corrective actions pending. Therefore, the agency is not 

required to provide a final response to this report. However, if you choose to provide a final response, 

we will post your response on the OIG’s public website, along with our memorandum commenting on 

your response. You should provide your response as an Adobe PDF file that complies with the 

accessibility requirements of Section 508 of the Rehabilitation Act of 1973, as amended.

We will post this report to our website at http://www.epa.gov/oig. 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

THE INSPECTOR GENERAL
EPA Needs to Demonstrate Public Health Benefits 15-P-0032

of Drinking Water State Revolving Fund Projects

Table of Contents

Purpose...................................................................................................................... 1

Background ............................................................................................................... 1

Responsible Office.................................................................................................... 3

Scope and Methodology........................................................................................... 3

Results of Review ..................................................................................................... 4

EPA Oversight of States Does Not Include Reviews 

 of Long-Term Public Health Outcomes 

and Interim Indicators for DWSRF Projects .................................................. 4

EPA and States Identified Ways to

 Demonstrate Public Health Benefits ...................................................... 5

Analysis Shows Systems Regained Compliance

 Which Indicates Public Health Improvements,

 But EPA Needs to Enhance Data Quality, Collection and Integration ............ 6

 Conclusion ................................................................................................................ 8

Recommendations .................................................................................................... 8

 Agency Comments and OIG Evaluation .................................................................. 9

Status of Recommendations and Potential Monetary Benefits ............................. 10

Appendices

A Agency Response .............................................................................. 11

B Distribution.......................................................................................... 14
15-P-0032 1

Purpose

We conducted this review to determine how the U.S. Environmental Protection 

Agency (EPA) and states demonstrate that completed Drinking Water State 

Revolving Fund (DWSRF) projects met project and program goals and 

contributed to improved drinking water and public health. 

Background

The 1996 Safe Drinking Water Act (SDWA) Amendments, in part, authorize the 

EPA to provide funding for capitalization grants to states. SDWA subsection 1452 

(b)(3)(A)(i-iii) establishes priorities for the use of funds. The states use these 

funds to support low interest loans and other types of assistance to public water 

systems (e.g., construction of new or improvements to existing water treatment 

plants and other infrastructure). The SDWA requires the states, to the extent 

practicable, to prioritize their projects that: (1) address the most serious risk to 

human health, (2) are necessary to ensure compliance with the requirements of the 

SDWA, and (3) assist systems most in need according to state affordability 

criteria. The EPA conducts annual reviews encompassing certain aspects of the 

states’ programs. According to the DWSRF Operations Manual, regions annually 

review and approve state Intended Use Plans/Project Priority Lists and evaluate 

state DWSRF program activity over the previous year. Specifically, the regions 

are required to evaluate the DWSRF programs’ finances and operations, and 

check their compliance with relevant statutes, regulations and grant conditions. 

The regions also assess the states’ progress and performance in achieving the 

goals and objectives identified in the states’ Intended Use Plans and reported 

through the state’s annual reports.

The EPA DWSRF capitalization grant agreements direct states to inform the EPA 

about project-level data on a quarterly basis. The EPA grant conditions require 

that each state DWSRF program provide public health protection results and 

progress in achieving program outputs and outcomes. Further, the GPRA 

Modernization Act of 2010 (GPRA refers to the 1993 Government Performance 

and Results Act) requires all federal agencies to have long-term goals that are 

supported by interim performance indicators. The EPA assesses drinking water 

quality through two national measures: (1) percent of the population served by 

community water systems that receive drinking water that meets all applicable 

health-based drinking water standards through approaches including effective 

treatment and source water protection, and, (2) percent of community water 

systems that meet all applicable health-based standards through approaches that 

include effective treatment and source water protection. According to the Office 

of Water, the EPA DWSRF program supports these national goals by 

demonstrating through Public Water System Supervision (PWSS) compliance 

monitoring that these systems are achieving drinking water standards captured by 

the EPA’s Safe Drinking Water Information System (SDWIS).
15-P-0032 2

The DWSRF program has comprised roughly 10 percent of the EPA’s overall 

budget appropriation in recent years. According to the agency, the EPA started 

requiring states to report project-level information into a Project and Benefits 

Reporting (PBR) system in 2009. The EPA aggregates this information into the 

National Information Management System for reporting purposes. According to 

the DWSRF Operations Manual, state DWSRF programs must conduct final 

inspections to ensure that funded projects were used for eligible purposes and 

completed in accordance with original plan specifications. These programs

manage project-level information through the PBR based on EPA grant reporting 

requirements. 

The PBR and National Information Management System databases identify four 

types of projects: 

 Compliant systems receiving funds to maintain compliance.

 Noncompliant systems receiving funds to return to compliance.

 Compliant systems receiving funds for issues unrelated to compliance. 

 Compliant systems receiving funds to meet future requirements.

From 2009 through 2013, 4,706 systems received $11.37 billion in funding from 

state revolving funds. Using the EPA’s four-part categorization scheme, this 

encompassed:

 2,544 compliant systems receiving $5.76 billion (51 percent of the total) 

to maintain compliance.

 1,173 noncompliant systems receiving $3.88 billion (34 percent of the 

total) to achieve compliance (higher risk).

 856 compliant systems receiving $1.26 billion (11 percent of the total) 

for issues unrelated to noncompliance.

 133 compliant systems receiving $468 million (4 percent of the total) to 

assist in obtaining future compliance.
15-P-0032 3

Chart 1: $11.37 billion spent on DWSRF projects 1

Source: The EPA’s PBR System.

Responsible Office

The EPA’s Office of Groundwater and Drinking Water (OGWDW) is responsible 

for implementing the SDWA. This office’s Drinking Water Protection Division 

oversees the implementation of the act by developing and helping implement 

national drinking water standards, overseeing and assisting funding of state 

drinking water programs and source water protection programs, helping small 

drinking water systems, protecting underground sources of drinking water, and 

providing information about drinking water quality to the public. The effort to 

improve public health protection for persons served by small drinking water 

systems (which account for more than 97 percent of public water systems in the 

United States) by strengthening the technical, managerial and financial capacity 

of those systems is an Agency Priority Goal for OGWDW. 

Scope and Methodology

We conducted this performance audit in accordance with generally accepted 

government auditing standards. Those standards require that we plan and perform 

the audit to obtain sufficient, appropriate evidence to provide a reasonable basis 

for our findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. We conducted our audit from 

November 2013 through August 2014.

To answer our objective, we identified relevant laws and guidance used by the

DWSRF program. We interviewed and surveyed EPA headquarters and regional 

staff, and analyzed national data on DWSRF projects and compliance. We also 

selected a sample of DWSRF projects to assess compliance data after the projects 

were completed and interviewed selected state DWSRF staff in Region 3 

 

1 The portion of projects selected for our sample came from water systems that received ‘Assistance to Achieve 

Compliance.’ This portion is in red in the chart. 

$5.76 B (51%)

$3.88 B (34%)

$1.26 B (11%) $468 M (4%)

Maintain compliance Achieve compliance

Unrelated to compliance Future compliance
15-P-0032 4

(Pennsylvania), Region 5 (Illinois) and Region 8 (Colorado and Wyoming) about

specific projects in our sample. 

Results of Review 

The EPA does not obtain all required DWSRF project data from states. The EPA 

also does not always use annual reviews of state DWSRF programs to assess

project outcomes. Without this information the EPA cannot determine whether 

completed DWSRF projects contributed to improved drinking water quality and 

public health. 

The SDWA gives the EPA the authority to make capitalization grants to state 

programs to further public health objectives and promote efficient use of funds. 

To support these objectives, the EPA capitalization grants require states to input 

key project information into the PBR and the National Information Management 

System databases. In addition, the GPRA Modernization Act of 2010 requires all 

federal agencies to have long-term goals that are supported by interim 

performance indicators. The EPA requires states to systematically provide 

information that can be used to assess project results. However, not all states 

report complete, required information in every instance. Our analysis shows that 

after systems received DWSRF funding, they regained compliance which 

indicates public health improvements, however, incomplete reporting affects 

value of the analysis for the DWSRF program. These incomplete data hamper the 

EPA’s ability to evaluate program effectiveness and public health outcomes.

As a result, the EPA is unable to demonstrate the public health results of this large 

agency expenditure. Further, the EPA cannot, in some cases, illustrate the overall 

success or challenges of specific DWSRF projects. The EPA is also missing an 

opportunity to capture and disseminate potential best practices of state programs 

and projects.

EPA Oversight of States Does Not Include Reviews of Long-Term 

Public Health Outcomes and Interim Indicators for DWSRF Projects

The EPA does not measure the results obtained from the projects funded by the 

DWSRF. The EPA does not use interim indicators, such as successful project 

completion nor long term outcome measures such as compliance information 

tracked in SDWIS. As a result, the DWSRF program is unable to demonstrate the 

public health results of these projects and in some cases, illustrate the overall 

success of the DWSRF program.

There is an opportunity to discuss and capture project outcomes during annual 

state/regional DWSRF program reviews and also at project completion. However, 

the EPA does not always take advantage of these opportunities. The DWSRF 

Program Operations Manual requires that each state DWSRF program submit an 

annual report to its EPA regional office detailing the state’s performance and its 
15-P-0032 5

compliance with DWSRF regulations including capitalization grant requirements.

The EPA grant conditions require that each state DWSRF program demonstrate

progress in achieving outputs and outcomes. However, we found that EPA

DWSRF regional staff do not always focus on project outcomes during annual 

reviews. Staff from one of the EPA regions shared that, during the annual review, 

there is limited consideration of public health benefits. These EPA regional staff 

explained that this may be due to the fact that health benefits are strongly 

considered up front. The EPA’s annual review checklist directs regional staff to 

focus on grant and programmatic compliance issues along with financial and 

managerial compliance. According to headquarters staff, project outcomes may be 

discussed during the annual review, if appropriate. However this is not routine. 

The EPA and states holding discussions about the public health benefits of 

projects during the annual review would be an important first step in measuring

long term outcomes for the program. These discussions would enhance the EPA 

regions and states’ ability to meet the requirements contained in the Operations 

Manual and grant conditions.

In addition to annual reviews, the EPA requires that state DWSRF programs 

conduct final inspections at project completion to determine whether funded 

projects were used for eligible purposes and completed in accordance with 

original plan specifications. However, the EPA does not have a corresponding 

requirement that the states enter the results of these inspections (or similar project 

completion information) into the PBR. This is a missed opportunity to capture 

individual project results for future analysis and program improvement. This 

information source could serve as a positive interim indicator for overall program 

success.

Further, according to the Office of Water, descriptions of DWSRF-financed 

projects could be more specific to include the compliance objective(s) to be 

addressed by the funding. This improvement in reporting would establish a clear 

connection between the funds and the public health outcomes that could be tested 

by examining the compliance monitoring results after the completion of the 

project’s construction.

EPA and States Identified Ways to Demonstrate Public Health 

Benefits 

We asked EPA headquarters and regional DWSRF staff to identify ways in which 

information might be collected to track whether projects contributed to improved 

drinking water quality and public health. Headquarters DWSRF staff suggested 

that we compare project level information in the PBR to compliance data in the 

Safe Drinking Water Information System (SDWIS). Nine of the 10 regions we 

surveyed suggested ways that data could be analyzed to track whether projects 

contributed to improved public health and water quality using data already 

available in the SDWIS and the PBR. Specifically, 
15-P-0032 6

 Four regions proposed combining information from the SDWIS and the 

PBR.

 Three regions proposed using the SDWIS database. 

o Two of these regions proposed assessing whether there are changes 

in water system compliance status. 

o One region proposed having the ability to generate summaries of 

DWSRF funding by water system.

 One region proposed that the PBR could be more user-friendly allowing 

for more data querying and reporting.

 One region proposed that tracking public health benefits of DWSRF 

projects should be discussed with key representatives who would be 

potentially impacted.

Staff from one state supported the idea of having a way to collect the 

environmental benefits of DWSRF projects. They further commented that 

involvement from their public water system departments would also be necessary,

as those departments have more information. 

Analysis Shows Systems Regained Compliance Which Indicates 

Public Health Improvements, But EPA Needs to Enhance Data 

Quality, Collection and Integration

We sampled the EPA data and public drinking water system information for the 

“Assist Non-Compliant Systems to Achieve Compliance” category for before and 

after project completion from 2009 through 2013. We chose this category because 

we expected that there would be a noticeable difference in system compliance 

before and after the DWSRF projects ended. Our results indicated that a large 

majority of projects and overall expenditures appear to have achieved positive 

results as measured by returning to compliance. However, these are not concrete 

conclusions because missing data in our sample, such as compliance period begin

and end dates, may affect actual results. Given the limitations, we found:

• 347 of 370 systems (93.8 percent) had no reported violations after the 

project completion.

• 23 of 370 systems (6.2 percent) had reported violations after project 

completion. 

o 18 of those 23 systems had only reporting or monitoring violations 

where the system failed to file a monitoring report for a regulated 

contaminant (4.9 percent).

o Five of those 23 systems had contaminant-related violations after 

project completion (1.4 percent).

These results show positive indications that the DWSRF project investments are 

beneficial, as the majority are achieving and maintaining compliance. Despite 

these positive indications, the EPA’s incomplete data hampers tracking of public 
15-P-0032 7

health outcomes. The following analysis showed several limitations that prevent a 

full evaluation of results, including:

 Required data fields in the PBR were incomplete. For example, out of our 

sample of 370 projects in the category of ‘assisting non-compliant systems 

to achieve compliance’, 172 (46 percent) were missing one or more data 

elements. Specifically, 29 projects did not have project start dates listed, 

and 36 projects were missing or did not have complete Public Water 

System identification numbers (unique identification numbers used for all 

public water systems). 

 Compliance dates were missing in the SDWIS database. Records for 

77 projects indicated noncompliance without a beginning date, and 

169 projects indicated noncompliance, but did not have a date for 

returning to compliance. Of the 23 projects that had violations 

post-DWSRF funding, 14 had violations with no indication that they had 

returned to compliance (some violations may be ongoing and not yet 

reported).2

These data quality limitations show that states are not always compliant with EPA 

grant requirements. The EPA requires, per the capitalization grant agreements, 

that states enter project level data about proposed public health benefits, project 

begin and end dates, and system identification into the PBR. Our data review

shows that states are not inputting all of this information. These data limitations 

prevented us from comprehensively evaluating DWSRF projects and hamper the 

EPA’s ability to evaluate overall DWSRF program effectiveness. As a result, the 

EPA is impeded in its ability to determine the extent to which expected results are 

achieved.

Additionally, we found that the EPA PWSS and DWSRF programs have not 

coordinated their respective databases to link compliance monitoring data to 

DWSRF project investment data. The EPA DWSRF headquarters program staff 

expressed that they would like to retrospectively review DWSRF projects, but due 

to oversight and management responsibilities, have not been able to do so. An 

Office of Water official stated that their office has compared DWSRF and PWSS

data on a case-specific basis in the past, but could do this routinely if DWSRF and 

PWSS program datasets were linked. 

By linking information in these systems, the agency then could assess compliance 

monitoring results after the completion of the project’s construction. Drawing the 

link between specific DWSRF investments in public water systems and their 

impact on particular communities is needed. The public needs to know how this 

large agency investment benefited the drinking water supply.

 

2 The systems with missing data are counted in more than one missing value category. 
15-P-0032 8

According to Office of Water staff, the EPA is currently planning to consolidate 

DWSRF tracking systems to allow project level data to be aggregated to provide 

state and national financial reports. The EPA, while consolidating data systems,

could use this as an opportunity to improve data collection and require certain 

data fields to incorporate tracking project public health results. The EPA would be 

able to determine the completed DWSRF projects that could potentially 

demonstrate public health outcomes.

Conclusion

After DWSRF projects are completed, nearly all water systems appear to be in 

compliance with health-based drinking water standards. While this is 

encouraging, currently the agency is unable to determine that completed DWSRF 

projects contribute to improved public health because of incomplete data and lack 

of data integration in the PBR and SDWIS databases. 

The complexities of drinking water infrastructure improvements make it difficult 

for the EPA to confidently attribute completed DWSRF projects to improvement 

in public health. However, the EPA could track interim indicators, long-term 

public health impacts, and improve data quality, collection and integration for 

selected types of DWSRF-funded projects. The public needs to be informed of the 

extent to which this large agency investment benefits the drinking water supply.

The fact that the EPA is currently upgrading the SDWIS database and proposing 

to consolidate DWSRF tracking systems provides the agency a cost-effective 

opportunity to modify data systems to allow it to assess the feasibility of tracking 

project results. The EPA should take advantage of this opportunity to provide 

further assurance that state programs are meeting SDWA requirements. By doing 

so, the EPA could support states in identifying how DWSRF investments 

contributed to improved public health. 

Recommendations

We recommend that the Assistant Administrator for Water:

1. Enforce the grant requirement for states to input all necessary data in the 

PBR database (e.g., project completion, project results, project start/end 

dates, compliance period begin/end dates, and public water system

identification numbers).

2. Review state-level data entry to ensure data completeness in the PBR

database as part of the EPA’s annual review of state performance.

3. Implement the most cost-effective method to capture public health 

benefits by using information gathered in state annual reviews and 

enhancing coordination with compliance monitoring programs at the 

federal and state levels. 
15-P-0032 9

4. Periodically evaluate program results to ensure that program goals are 

being achieved at water systems receiving DWSRF financial assistance,

and record successes, best practices and challenges to be shared among 

EPA regions and the states to focus and enhance program performance.

Agency Comments and OIG Evaluation

The Office of Water agreed with all recommendations and provided projected 

completion dates. Therefore, the recommendations are resolved with 

corrective actions pending. We also received technical comments from the 

Office of Water, which are incorporated into the report as appropriate. In its 

response, the Office of Water said that the data we reviewed for this report 

revealed a high indication of public health protection from DWSRF funds. 

While the results of our sample show positive indications, the EPA’s 

incomplete data hampers tracking of public health outcomes. In addition, the 

EPA needs to systematically demonstrate how project results contribute to 

public health.
15-P-0032 10

Status of Recommendations and 

Potential Monetary Benefits

RECOMMENDATIONS

POTENTIAL MONETARY 

BENEFITS (in $000s)

Rec. 

No.

Page 

No. Subject Status1 Action Official

Planned 

Completion 

Date

Claimed 

Amount

Agreed-To 

Amount

1 8 Enforce the grant requirement for states to input all 

necessary data in the PBR database (e.g., project 

completion, project results, project start/end dates, 

compliance period begin/end dates, and public 

water system identification numbers).

O Assistant Administrator 

for Water

4/30/15

2 8 Review state-level data entry to ensure data 

completeness in the PBR database as part of the 

EPA’s annual review of state performance.

O Assistant Administrator 

for Water

12/31/14 2

3 8 Implement the most cost-effective method to 

capture public health benefits information by using 

information gathered in state annual reviews and 

enhancing coordination with compliance monitoring 

programs at the federal and state levels.

O Assistant Administrator 

for Water

3/31/15

4 9 Periodically evaluate program results to ensure that

program goals are being achieved at water 

systems receiving DWSRF financial assistance and 

record successes, best practices and challenges to 

be shared among EPA regions and the states to 

focus and enhance program performance.

O Assistant Administrator 

for Water

12/31/14

1 O = Recommendation is open with agreed-to corrective actions pending.

C = Recommendation is closed with all agreed-to actions completed.

U = Recommendation is unresolved with resolution efforts in program.

2 While the Office of Water cited an earlier date in its response to the draft report, the Office of Water subsequently indicated it will not complete the 

action until December 31, 2014.
15-P-0032 11

Appendix A

Agency Response

MEMORANDUM

SUBJECT: Response to Office of Inspector General Draft Report No. OPE-FY-0009, “EPA 

Needs to Demonstrate Public Health Benefits of Drinking Water State Revolving Fund 

Projects,” dated August 1, 2014 

FROM: Kenneth J. Kopocis

Deputy Assistant Administrator

TO: Arthur A. Elkins, Jr.

Inspector General

Thank you for the opportunity to respond to the issues and recommendations in the subject audit 

report. Following is a summary of the U.S. Environmental Protection Agency’s overall position, 

along with its position on each of the report recommendations. For the report recommendations, 

with which the EPA agrees, we have provided high-level intended corrective actions and 

estimated completion dates. We have also attached technical comments on the report for your 

consideration. 

AGENCY’S OVERALL POSITION

The EPA’s Office of Water/Office of Ground Water and Drinking Water has worked to ensure 

public health benefits of the Drinking Water State Revolving Fund through integration with the 

Public Water System Supervision program. Both programs are driven to maximize the same 

internal measures established for the National Water Program in 1997:

(1) The percent of the population served by community water systems that receive 

drinking water that meets all applicable health-based drinking water standards 

through approaches including effective treatment and source water protection.

(2) The percent of community water systems that meet all applicable health-based 

standards through approaches that include effective treatment and source water 

protection.

In 2006 the Director of the OW/OGWDW wrote a memorandum to Regional Water Division 

Directors indicating that coordination of the DWSRF and PWSS programs is essential to SDWA 

implementation and underscoring the importance of integrating these mutually-reinforcing 

programs. Available data examined for the subject draft report support that intended public 

health benefits are being achieved for consumers of water systems receiving DWSRF financial 

assistance. The Inspector General’s comparison of results of the DWSRF Project and Benefits 

Reporting System (PBR) and the Safe Drinking Water Information System (SDWIS) shows that 

93.8 percent of water systems (347 of 370 systems) had no reported violations after DWSRF-
15-P-0032 12

funded project completion. Additionally, of the 6.2 percent of systems with reported violations, 

only five systems (1.4 percent of the total) had violations due to the presence of contaminants. 

Notwithstanding this high indication of public health protection, the EPA agrees that more can 

be done to integrate the results of the two information systems. We are currently working on a 

pilot effort using FY 2013 data to complete a comparison of violations in SDWIS with project 

completion status in PBR (through electronic spreadsheet analysis) to integrate results without 

the expense of database modification. 

AGENCY’S RESPONSE TO REPORT RECOMMENDATIONS

Agreements

No. Recommendation High-Level Intended Corrective 

Action(s)

Estimated Completion by FY

1 Enforce the grant 

requirement for states to 

input all necessary data 

in PBR (e.g., project 

completion, project 

results, project start/end 

dates, compliance 

period begin/end dates, 

and public water system 

identification numbers).

The OW/OGWDW agrees with 

the intent of this recommendation 

as a path to mutual data quality 

objectives, which we share with 

the IG. We take lack of reporting 

seriously and will work with 

Regions and states to ensure 

receipt in PBR of complete data 

for projects receiving DWSRF 

financial assistance as provided for 

in grant terms and conditions. To 

support complete data reporting, 

we will also be doing further 

analysis of data completeness in 

PBR.

The OW/OGWDW will 

provide Regions a report of 

completeness of required 

DWSRF project data 

beginning in April 2015 and 

quarterly thereafter. The 

Regions will be able to 

identify with states the 

actions needed for states to 

provide complete data for 

projects receiving DWSRF 

financial assistance and to 

oversee steps to accomplish 

complete reporting of 

required data. Where 

incomplete reporting of 

required data continues to be 

a problem, the 

OW/OGWDW will consult 

with the Region on taking 

appropriate corrective action.

2 Review state-level data entry 

to ensure data completeness in 

PBR as part of the EPA’s 

annual review of state 

performance.

The OW/OGWDW agrees with 

this recommendation and will 

provide guidance for the annual 

review process and checklist that 

includes checking on completeness 

of the states’ data reported in PBR 

for reviews in FY 2015.

September 2014.

3 Implement the most costeffective method to capture 

public health benefit 

The OW/OGWDW agrees with 

this recommendation and has 

initiated data integration of the 

March 2015.
15-P-0032 13

information by using 

information required in state 

annual/biennial reports and 

enhancing coordination with 

compliance monitoring 

programs at the federal and 

state levels.

PBR and SDWIS data sets to 

identify completed projects 

receiving DWSRF financial 

assistance which were in violation 

after project completion. The 

OW/OGWDW will develop a 

regular report for use by Regions 

and states to document the public 

health results of the DWSRF 

financial assistance.

4 Periodically evaluate program 

results to ensure that program 

goals are being achieved at 

water systems receiving 

DWSRF financial assistance 

and record successes, best 

practices and challenges to be 

shared among the EPA 

regions and the states to focus 

and enhance program 

performance.

The OW/OGWDW agrees with 

this recommendation. The 

OGWDW conducts an annual 

review of the program through the 

Regional offices’ focused reviews 

of state program outputs for the 

prior year. OW/OGWDW will 

continue to evaluate program 

results and achievement of 

program goals as well as 

determine what actions are 

necessary to achieve results where 

needed. The reviews will also 

record successes, best practices 

and challenges to share among 

Regions and states.

December 2014 and annually 

thereafter.

CONTACT INFORMATION

If you have any questions regarding this response, please contact Charles Job, Chief of the 

Infrastructure Branch in the OW/OGWDW, at (202) 564-3941 or job.charles@epa.gov.

cc: Dan Engelberg

 Carolyn Cooper 

 Marilyn Ramos
15-P-0032 14

Appendix B

Distribution

Office of the Administrator 

Deputy Assistant Administrator for Water 

Agency Follow-Up Official (the CFO) 

Agency Follow-Up Coordinator 

General Counsel

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for Public Affairs

Principal Deputy Assistant Administrator for Water

Audit Follow-Up Coordinator, Office of Water